Allergen Management Controls to Avoid Product Recalls

Food Allergens are considered chemical food safety hazards and, in some cases, can cause adverse health consequences to individuals with food allergies. It is estimated that anywhere between 3-6% of kids and 2-4% of adults in the US have some level of food allergy. It is impossible to estimate the exact percentage of the population with food allergies as some people either ignore the symptoms or are unaware that the condition they experience is a food allergy. For example, people having stomach issues after eating certain foods tend to say, “this food doesn’t agree with me”. Stomach problems including diarrhea are one of the symptoms of food allergies. Allergens can cause minor symptoms like tangling of lips or skin rush but in some cases can be more severe and include cardiovascular issues (loss of blood pressure) and anaphylactic shock which is a life-threatening condition.

In the US regulatory system there is a regulation called “Food Allergen Labeling and Consumer Protection Act of 2004”. This is the regulation outlining the eight major food allergens and the rules for identification and labeling on food products. In addition to this regulation, in 2004 the President signed FASTER act introducing sesame seed as the nineth major food allergen in the US. The complete list of major food allergens in the US includes the following foods: milk, soy, egg, wheat, fish, shellfish, tree nuts, peanuts and sesame seed. Tree nuts, fish and shellfish are species specific which means the manufacturers must state the actual type of the food within the category. Major food allergens are responsible for over 90% of allergy reactions. Keep in mind that the list of the major food allergens in the US varies from allergen lists in other countries. Canada additionally recognizes barley and mustard seeds as allergens. In the EU celery, mustard seeds and different types of beans are considered allergens.

According to Reportable Food Registry, undeclared food allergens make up almost 40% of all product recalls. The root causes for undeclared allergens on product labels vary from using the wrong packaging or ingredient, not declaring allergens by their common name to human error during changeover and when verifying labels. Facilities producing food for retail sale are obligated to follow allergen labeling regulations. This includes not only the above-mentioned labeling regulations but also Current Good Manufacturing Practices and Risk Based Preventive Controls for Human Food – 21 CFR 117. GMP regulatory guideline from both regulatory agencies (USDA and FDA) requires that facilities prevent allergen cross contact. This is achieved through number of controls starting from adequate ingredient receiving and storage practices, scheduling controls on production lines, physical and engineering controls including physical barriers and finally cleaning activities when running allergens and non-allergens on shared equipment. Both Preventive Controls and USDA / FDA HACCP regulations require that food products are properly labeled including a proper allergen declaration. This is to ensure that individuals with food allergies are provided with accurate information to avoid foods that may harm them.

All activities related to allergen cross contact prevention and labeling require personnel training. Training Programs must be tailored to production facilities and specific conditions at those facilities. This includes general training for hourly employees and job specific training for inspection personnel. Individuals managing the food safety systems must also be properly trained and depending on the food sector category this may including International HACCP Alliance accredited HACCP training or FDA recognized FSPCA Preventive Controls Qualified Individual (PCQI) Training. Lack of appropriate training may have an adverse effect on the design of the company’s food safety system, including allergen management and on employee practices that may lead to cross contact or mislabeling. As a food business you should invest in your personnel by providing sufficient training resources. At BD Food Safety Consultants, we offer a variety of training options including HACCP, PCQI, HACCP / SQF Overview and others. Visit our website today to see which training is relevant to your operation – https://bdfoodsafety.com/training-programs/